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PY26 WHEAP Manual

137 Revised: August 2025 6. Any other records that support charges incurred

Agencies shall maintain sufficient segregation of accounting records for this program separate from other contracts, projects, and programs.

9.4.5 Open Records/Public Records An agency is subject to State Public Record laws, (Wisconsin Statutes §19.21-19.39). These laws relate to record retention by the agency and to the provision of information (known as “complete public access”). Division policy is to: 1. Forward a written copy of all records requests to DOA, DEHCR or directly to DOA, Office of the Secretary, Legal Office, PO Box 7864, Madison, WI 53707-7864, and 2. Provide records to requestors, as required, or 3. Request that DOA coordinate the response to the records request.

9.4.6 Financial Audits Agencies shall ensure that financial audits are: 1. Conducted annually 2. Conducted by an independent auditor 3. Timely 4. Submitted to the Division as soon as available. Audit reports, including any accompanying letter of findings should be emailed as a text searchable, unsecured PDF file to: DOABFMSingleAuditCoordinator@wisconsin.gov 5. Conducted in accordance with federal laws and regulations, OMB Circular A-133 and the State Single Audit Guidelines (SSAG) issued by the WI DOA. Current SSAG for DOA is available online.

9.5 Administrative Requirements Each WHEAP agency is required to operate WHEAP under the administrative standards in this section.

9.5.1 Conflict of Interest Policy Each WHEAP agency shall develop*, implement, and keep on file a plan/written policy for managing potential conflicts of interest. Conflicts of interest covered by the plan/written policy shall include all situations, actual or perceived, when the agency, agency staff, members and relatives of the agency’s board of directors, and friends and relatives of agency staff may receive personal benefits or employment from WHEAP. At a minimum, the policy shall set forth the procedures and steps the agency will follow to address the following situations: • Agency staff processing WHEAP applications for which they have a familial, financial, or other connection to the case head, household members, landlord, or other party that would benefit either directly or indirectly from approval of the application • Hiring and supervising agency staff to avoid nepotism.